Check how your business can still use chemicals once the UK leaves the EU

We hope you find our news updates useful. If you know of anyone who may benefit from reading them, please encourage them to register at the bottom-left of our news page (http://www.eljay.co.uk/news/) and we’ll email them a link each time an update is published. If in the unlikely event any difficulties are experienced whilst registering we’ll be more than happy to help and can be contacted on 07896 016380 or at Fiona@eljay.co.uk

If the UK leaves the EU without a deal, and you are a company that makes, supplies or uses chemicals, there may be changes that affect your business.

Your business may need to make changes before the UK leaves the EU. Please visit Prepare for EU Exit (https://www.gov.uk/euexit) to find more detailed guidance on policy changes relevant to your sector and to sign up for updates.

Importing and exporting

Preparing for disruption to trade at the UK-EU border

  1. Get a UK Economic Operator Registration and Identification (EORI) number (https://www.gov.uk/guidance/get-a-uk-eori-number-to-trade-within-the-eu) so you can continue to import or export goods and apply for authorisations that will make customs processes easier for you.
  2. Decide if you want to hire an import-export agent, or make the declarations yourself (https://www.gov.uk/guidance/declaring-your-goods-at-customs-if-the-uk-leaves-the-eu-with-no-deal)
  3. Contact the organisation that moves your goods (for example, a haulage firm) to find out what information they need to make the declarations for your goods, or if you will need to make them yourself.

Read the guidance on simplified customs procedures for trading with the EU if we leave without a deal: https://www.gov.uk/guidance/customs-procedures-if-the-uk-leaves-the-eu-without-a-deal

Further information is provided in HMRC’s advice for businesses trading with the EU: https://www.gov.uk/government/publications/no-deal-brexit-advice-for-businesses-only-trading-with-the-eu

Preparing for changes to existing trade agreements

Check the way you currently trade with non-EU countries. When the UK leaves the EU the way you access existing favourable arrangements with these countries may change. Changes may be different for each country.

Read the guidance on changes to trading with non-EU countries that have a free trade agreement with the EU: https://www.gov.uk/government/publications/existing-trade-agreements-if-the-uk-leaves-the-eu-without-a-deal/existing-trade-agreements-if-the-uk-leaves-the-eu-without-a-deal

Preparing for changes to import tariffs

If the UK leaves the EU without a deal, the UK would implement a temporary tariff regime. This would apply for up to 12 months while a full consultation, and review on a permanent approach, is undertaken.

Under the temporary tariff regime the majority of UK imports would be tariff-free.

In certain sectors, tariffs would be maintained to support the most sensitive agricultural industries, the automotive sector, vulnerable industries exposed to unfair global competition, and to maintain the UK government’s commitment to developing countries.

Check the temporary rates of customs duty on imports after EU Exit: https://www.gov.uk/guidance/check-temporary-rates-of-customs-duty-on-imports-after-eu-exit

Regulation and standards

Chemical regulations

After the UK leaves the EU there will be changes to all chemical regulations, including EU REACH (the Registration, Evaluation, Authorisation and Restriction of Chemicals Regulation).

If the UK leaves the EU without a deal, the EU REACH regulations will be brought into UK law to create ‘UK REACH.’

Maintain your access to EU/EEA market

If the UK leaves the EU without a deal, you will need to transfer your registrations to an EU/EEA-based organisation or support your EU/EEA-based importers to become registrants. Read the guidance from the European Chemicals Agency (EHCA): https://echa.europa.eu/uk-withdrawal-from-the-eu

Maintain access to UK markets

If you are a business based in the UK with an EU REACH registration, your registration will be legally recognised in UK REACH. However, you will need to take action to validate your grandfathered registration.

You will need to:

  • open an account on REACH IT once it is established and provide initial information on your registration within 120 days of the UK leaving the EU
  • provide full technical information on your registration within 2 years of the UK leaving the EU

Further information is provided on the HSE website: http://www.hse.gov.uk/brexit/reach.htm

UK-based downstream user or distributor of an EU REACH registered substance

If you currently purchase a chemical substance directly from an EU/EEAsupplier, you must make sure any substances you purchase are covered by a valid UK REACH registration by someone within your supply chain. In order to remain compliant by registering as an ‘importer’, you must:

  • open an account on REACH IT and provide initial information on your registration within 180 days of the UK leaving the EU
  • provide full technical information on your registration within 2 years of the UK leaving the EU.

Read the guidance on regulating chemicals if the UK leaves the EU without a deal: https://www.gov.uk/government/publications/regulating-chemicals-reach-if-theres-no-brexit-deal/regulating-chemicals-reach-if-theres-no-brexit-deal and the chemical regulation guidance from HSE: http://www.hse.gov.uk/brexit/reach-guidance.htm

You might also have to take some actions if you deal with:

Energy and climate

Participating in the EU Emissions Trading Scheme (EU ETS)

If the UK leaves the EU without a deal, then the EU rules governing the EU ETS would no longer apply to the UK.

Business emissions from 1 January 2019 onwards will no longer be covered by the EU ETS, so UK businesses would no longer need to surrender allowances for these emissions at the end of each year.

However, all stationary installations currently participating in the EU ETS should continue to comply with the regulations for the monitoring, reporting and verification of greenhouse gases. These regulations will underlie the new UK Carbon Emissions Tax.

The UK Carbon Emissions Tax will be introduced on 1 April 2019 and the reporting period for stationary operators will be 1 April 2019 to 31 December 2019. The 2019 tax will be set at £16 per tonne. Subject to state aid approval, the scheme to compensate energy-intensive industries for the indirect costs of the EU ETS would remain in place to compensate for the indirect emission costs of the new Carbon Emissions Tax.

Accounts administered by the UK in the EU ETS allowance registry and Kyoto Protocol registry will be blocked from the point of the UK leaving the EU. Operators wishing to retain access to their allowances after the withdrawal date should consider opening an account in another member state’s registry for this purpose, and should consider the amount of time this is likely to take. Clean Development Mechanism project developers with a UK Letter of Authority will also need a letter of approval from a different Designated National Authority.

Until further notice, the UK government will not issue or auction any 2019 EU ETS allowances. It remains possible for allowances to be purchased through the European Energy Exchange (EEX) auction platform (http://www.eex.com/en/), and on the secondary market. Operators should consider this when planning to meet 2018 compliance obligations. To make sure your obligations will not be affected, the government brought forward the 2018 compliance year deadlines (https://www.gov.uk/government/consultations/bringing-forward-eu-emissions-trading-system-2018-compliance-deadlines-in-the-uk), published on 7 March 2018. This states that you need to report your 2018 emissions by 11 March 2019, and surrender allowances for those emissions by 15 March 2019.

Carbon Emissions Tax legislation is included in the Finance Bill 2018-19.

Read the guidance on meeting climate change requirements if the UK leaves the EU without a deal: https://www.gov.uk/government/publications/meeting-climate-change-requirements-if-theres-no-brexit-deal/meeting-climate-change-requirements-if-theres-no-brexit-deal and the Carbon Emissions Tax policy paper: https://www.gov.uk/government/publications/carbon-emmisions-tax/carbon-emmisions-tax

Your employees

Employing EU workers

If the UK leaves the EU without a deal, EU citizens who are resident in the UK before 29 March 2019 will be able to apply to the EU Settlement Scheme (https://www.gov.uk/settled-status-eu-citizens-families) to get settled or pre-settled status, which will mean they can continue to live, work and study in the UK.

The scheme will be open to applications from 30 March 2019 and EU workers must apply by 31 December 2020 if the UK leaves the EU without a deal.

You can use the EU Settlement Scheme guidance for employers (https://www.gov.uk/government/publications/eu-settlement-scheme-employer-toolkit) to give further information to your employees.

Applying for skilled-work or unskilled-work visas

If the UK leaves the EU without a deal, there will be a new process for EU citizens (https://www.gov.uk/guidance/european-temporary-leave-to-remain-in-the-uk) arriving in the UK before 31 December 2020. From 1 January 2021, a new skills-based immigration system (https://www.gov.uk/government/publications/the-uks-future-skills-based-immigration-system) will launch.

For non-EU nationals, EU Exit will not affect the application process for work visas.

Contains public sector information licensed under the Open Government Licence v3.0.

HEALTH & SAFETY NEWS UPDATE – 4TH AUGUST 2016

We hope you find our news updates useful. If you know of anyone who may benefit from reading them, please encourage them to register at the bottom-left of our news page (http://www.eljay.co.uk/news/) and we’ll email them a link each time an update is published. If in the unlikely event any difficulties are experienced whilst registering we’ll be more than happy to help and can be contacted on 07896 016380 or at Fiona@eljay.co.uk

How to carry out a COSHH risk assessment – worker dies from toxic gas

A medicinal herbal manufacturing company has been fined £45,000 after a worker died from exposure to a toxic gas.

The 50 year old employee was using cleaning chemicals to clean a changing room when he was exposed to a toxic gas (likely to be chlorine) and died at the scene.

An investigation by the Health and Safety Executive (HSE) into the incident which occurred in September 2014 found that he had not been trained in the safe use of chemicals and no company Control of Substances Hazardous to Health (COSHH) assessment had been carried out.

HM Inspector Stephen Farthing said: “This was a tragic industrial incident that was entirely preventable had suitable precautions been taken. [The employee] had not received any training in the safe use of hazardous chemicals and as a result died from the exposure to a toxic gas.

“Companies should ensure that they assess all the risks associated with the use of dangerous chemical and that exposure to their employees is either eliminated or minimised.”

How to carry out a COSHH risk assessment

A COSHH assessment concentrates on the hazards and risks from hazardous substances in your workplace.

Remember that health hazards are not limited to substances labelled as ‘hazardous’. Some harmful substances can be produced by the process you use, eg wood dust from sanding, or silica dust from tile cutting.

Identify the hazards

  • Identify which substances are harmful by reading the product labels and safety data sheets (SDS)
  • If you are in doubt, contact your supplier
  • Remember to think about harmful substances produced by your processes, such as cutting or grinding, or to which workers may be otherwise exposed

Decide who might be harmed and how

  • How might workers be exposed? Think about the route into the body (whether the substance can be breathed in, get onto or through the skin or can even be swallowed) and the effects of exposure by each of these routes
  • Think of how often people work with the substance and for how long
  • Think about anyone else who could be exposed
  • Don’t forget maintenance workers, contractors and other visitors or members of the public who could be exposed
  • Also think about people who could be exposed accidentally, eg while cleaning, or what happens if controls fail

Evaluate the risks and decide on precautions

Once you have carried out a risk assessment and identified which harmful substances are present, and how workers can be harmed, you need to think about preventing exposure.

  • Do you really need to use a particular substance, or is a safer alternative available?
  • Can you change the process to eliminate its use or avoid producing it? If this is not possible, you must put in place adequate control measures to reduce exposure

The measures you adopt could include the following:

Changing the process to reduce risks

  • Consider whether you can change the process you use to reduce the risk of exposure. For example, you could reduce the temperature of a process to reduce the amount of vapour getting into the air or use pellets instead of powders as they are less dusty

Containment

  • Enclose the process or activity as much as possible to minimise the escape or release of the harmful substance
  • Use closed transfer and handling systems and minimise handling of materials
  • Extract emissions of the substance near the source

Systems of work

  • Restrict access to those people who need to be there
  • Plan the storage of materials, and use appropriate containers. Check that storage containers are correctly labelled and that incompatible materials, for example acids and caustics, are separated
  • Plan the storage and disposal of waste

Cleaning

  • Exposure to hazardous substances can occur during cleaning, so plan and organise the workplace so that it can be easily and effectively cleaned
  • Smooth work surfaces will allow easy cleaning
  • Have the right equipment and procedures to clear up spillages quickly and safely
  • Clean regularly using a ‘dust-free’ method – vacuum, don’t sweep

If you have five or more employees, you must record your assessment but, even if you have fewer than five, it makes sense to write down what steps you have taken to identify the risks. And the really important part is making a list of the actions you have taken to control the risks to workers’ health.

The risk assessment should be regularly reviewed to ensure that it is kept up to date to take into account any changes in your workplace.

For more information, visit the HSE web page: http://www.hse.gov.uk/toolbox/harmful/coshh.htm or contact us on 07896 016380 or at fiona@eljay.co.uk, and we’ll be happy to help.

Contains public sector information published by the Health and Safety Executive and licensed under the Open Government Licence

 

 

HEALTH & SAFETY NEWS UPDATE – 3RD MARCH 2016

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IN THIS UPDATE

Introduction

Fairgrounds and amusement parks – HSE to prosecute Alton Towers’ owners after ‘Smiler’ incident

Temporary demountable structures – firm fined after circus tent collapse

Control of Substances Hazardous to Health (COSHH) – insulation company fined for health and safety failings

Introduction

The Health and Safety Executive has again been in the news over the last week, after informing Merlin Operations Ltd that it will be prosecuted over an incident in which five people were seriously injured on a rollercoaster ride at Alton Towers in Staffordshire. Two female passengers on the ‘Smiler’ ride suffered leg amputations and three others were also seriously injured when their carriage collided with a stationary carriage on the same track. The incident happened on 2 June 2015. We open this week’s update with HSE guidance on safe practice for fairgrounds and amusement parks.

Staying with the leisure industry, we also share HSE guidance this week on ‘temporary demountable structures’, following news of a marquee and tent supplier being fined after guy ropes securing a circus tent snapped causing it to collapse injuring three adults and five children at Burley Park, New Forest.

And finally, we close with HSE guidance on the Control of Substances Hazardous to Health (COSHH), following news of a Welsh insulation company that produced natural insulation products being fined £30,000 plus £59,000 costs for health and safety failings.

We hope you find our news updates useful. If you know of anyone who may benefit from reading them, please encourage them to register at the bottom-left of our news page (http://www.eljay.co.uk/news/) and we’ll email them a link each time an update is published. If in the unlikely event any difficulties are experienced whilst registering we’ll be more than happy to help and can be contacted on 07896 016380 or at Fiona@eljay.co.uk

Fairgrounds and amusement parks – HSE to prosecute Alton Towers’ owners after ‘Smiler’ incident

HSE media statement – 25th February 2016

The Health and Safety Executive (HSE) has today informed Merlin Attractions Operations Ltd that it will be prosecuted over an incident in which five people were seriously injured on a rollercoaster ride at Alton Towers in Staffordshire.

Two female passengers on the ‘Smiler’ ride suffered leg amputations and three others were also seriously injured when their carriage collided with a stationary carriage on the same track. The incident happened on 2 June 2015.

Merlin Attractions Operation Ltd based in Poole, Dorset, will appear at North Staffordshire Justice Centre, Newcastle-under-Lyme on 22 April 2016 to face a charge under the Health and Safety at Work Act etc, 1974.

Neil Craig, head of operations for HSE in the Midlands said:

“We have today informed Merlin Attractions Operations Ltd that it will be prosecuted for breaching health and safety law.

“This was a serious incident with life-changing consequences for five people.

“We have conducted a very thorough investigation and consider that there is sufficient evidence and that it is in the public interest to bring a prosecution.”

Merlin Attractions Operations Ltd is the company responsible for Alton Towers and under health and safety law is responsible for managing the risks created by the operation of the theme park’s rides.

Guidance on safe practice

Free to download by clicking on the following link: http://www.hse.gov.uk/pubns/books/hsg175.htm – revised guidance on what the Fairgrounds and Amusement Parks Joint Advisory Committee on Fairgrounds and Amusement Parks (FJAC) considers appropriate safe measures for the industry to adopt in order to comply with the law.

Although fairgrounds and amusement parks are relatively safe compared to activities such as driving a car or riding a bicycle, as we are all too aware, there have been a small number of serious incidents involving employees and members of the public. The Health and Safety Executive has worked with the members of the Fairgrounds and Amusement Parks Joint Advisory Committee to improve standards and to produce this revised guide.

Acknowledging the inherent nature of fairgrounds and describing how risks can be managed effectively, it also promotes a sensible, over-arching approach recognising that while users expect high safety levels from risks beyond their control, incidental elements, eg a dodgem bump, are considered ‘part of the fun’.

The guide, however, concentrates on the safety of employers and employees, as well as the public, and begins with the industry-specific ‘system for safety of attractions’ presented in easy table-form, which then steers the reader smoothly through the publication.

For more information, contact us on 07896 016380 or at Fiona@eljay.co.uk, and we’ll be happy to help.

Temporary demountable structures – firm fined after circus tent collapse

The owner of a company who supplies marquees and tents has been fined after guy ropes securing a circus tent snapped causing it to collapse injuring three adults and five children at Burley Park, New Forest.

Southampton Magistrates’ Court heard that on 10 August 2014 a sudden gust of wind went through the circus tent and eighteen of the guy ropes which secured the tent failed and snapped.

An investigation by the Health and Safety Executive (HSE) into the incident found that Happy Promotions Limited had in December 2013 taken their tent for inspection and repair to the marquee and tent supplier, who was asked to replace the guy ropes.

However, the court heard the guy ropes supplied were in fact made up of unrated webbing and had no safe working load. This led to the incident at Burley Park 8 months later.

HSE inspector Andrew Johnson said after the hearing: “The fact the guy ropes snapped (rather than the pegs being pulled from the ground) is a clear indication that the fault lies with the strength of the guy ropes, rather than the method of erection. Fortunately, the tent was empty at the time of the incident. Had a performance been underway there would have been performers and around 30 people were due to attend the afternoon performance. Were the tent occupied the collapse would likely have resulted in multiple serious injuries.”

Temporary demountable structures (TDS) – Stages, seating, marquees etc

Your duties as an event organiser

You are responsible for ensuring that as far as reasonably practicable, employees and others at a venue who could be affected by the construction and use of a TDS (such as scaffolders, riggers and members of the public) are not exposed to risks to their health and are kept safe from harm.

What you should know

Most fatal and serious injuries arise when workers fall during construction work or as a result of the collapse of the structure, lifting operations or mobile plant.

Checklist – TDS dos and don’ts

Do

Planning

  • Consider what the structure will be used for, what it needs to be able to do, who will use it and how?
  • Prepare a clear specification for the structure’s required use. This should include the technical details required to enable a design to be undertaken by your appointed TDS contractor(s) / designer (s).
  • TDS contractors / designers hired to design, supply, build, manage and take down a structure for you, should be competent and adequately resourced.
  • Provide TDS contractors / designers with relevant site information and/or allow them site access to carry out their own site assessments.
  • Your TDS contractor should ensure that the proposed structure has a design prepared by a competent person, which takes account of the use and conditions in which it is to be installed.
  • Where a structure is to carry advertising / scrim, include this requirement in any design concept, specification and structural assessment.
  • Novel or unusual structures may require additional testing by a TDS designer to demonstrate the integrity of the design.
  • Whoever builds the structure should undertake an assessment of the likely construction hazards and risks. To help with an assessment and to find out more about construction hazards and risks see:
  • Falls from height
  • Construction safety topics (including lifting operations and vehicle safety)
  • Health risks in construction
  • Plan and work with your contractors to develop safe systems of working and make sure all significant risks on the site are properly controlled, eg use of cranes and lift trucks.
  • Plan to minimise confusion and conflict, particularly between those contractors carrying out concurrent or consecutive activities on the same structure.
  • Consider the extent of control that you and your contractors have over the work activity and workplace during each phase of the build, use and deconstruction cycle of a structure. Organisers and TDS contractors should agree the extent of their control at the planning stage, so that responsibility for structural safety is understood and maintained throughout the event.

Building and dismantling the TDS

  • The assessments done under Planning (above) should serve as a guide on how to build and dismantle the structure safely.
  • Make sure there is sufficient time and resources available to build and dismantle the structure safely.
  • Use competent staff and have a suitable onsite operational management system in place to supervise and monitor safety compliance.
  • A programme of works, including key safety checkpoints, can be helpful to communicate critical erection / dismantling stages to the site manager / crew bosses and operatives.
  • Build the structure to the agreed design in accordance with a safe system of work.
  • Arrange for the structure to be checked to make sure that it has been built according to the design.

While TDS is in use

  • Have arrangements in place to inspect the structure for deterioration during the time it is installed in line with a documented management plan and, if needed, arrange for remedial works.
  • Any change in the proposed use of the structure or site conditions which may affect the structure’s suitability should trigger a design check for the new conditions. An example of this may be the requirement to add additional banners to a structure such as a PA tower. The organiser is responsible for ensuring this is done.
  • Have arrangements in place to ensure that any measures required to keep the structure safe during use are implemented. For example, if the structure is susceptible to the weather, monitor and measure the local weather conditions. In adverse weather conditions, know what to do with the structure to protect its stability, eg when to open wind relief panels and when to evacuate.

Don’t

  • Take forward incomplete design concepts, as this could result in last-minute modifications, leading to safety problems.
  • Build a structure on unstable ground.
  • Put advertising / scrim on a structure if a competent person has not approved it as being safe – it can affect wind loading and increase the risk of collapse / overturn.
  • Use flammable fabrics.

For more information, visit the HSE web page http://www.hse.gov.uk/event-safety/temporary-demountable-structures.htm, or contact us on 07896 016380 or at Fiona@eljay.co.uk, and we’ll be happy to help.

Control of Substances Hazardous to Health (COSHH) – insulation company fined for health and safety failings

A Welsh insulation company that produced natural insulation products have been fined £30,000 plus £59,000 costs for health and safety failings.

Wrexham Magistrates’ Court heard that the company failed to conduct an adequate risk assessment for the processing of hemp. They also failed to adequately guard machinery.

An investigation by the Health and Safety Executive (HSE) into the concerns raised anonymously found that the COSHH assessment was not suitable and sufficient.

Control of Substances Hazardous to Health (COSHH)

What is a ‘substance hazardous to health’?

COSHH covers substances that are hazardous to health. Substances can take many forms and include:

  • chemicals
  • products containing chemicals
  • fumes
  • dusts
  • vapours
  • mists
  • nanotechnology
  • gases and asphyxiating gases and
  • biological agents (germs). If the packaging has any of the hazard symbols then it is classed as a hazardous substance.
  • germs that cause diseases such as leptospirosis or legionnaires disease and germs used in laboratories.

COSHH does not cover

  • lead,
  • asbestos or
  • radioactive substances

because these have their own specific regulations.

What you need to do

Before you start your COSHH assessment, you need to:

Think about

  • What do you do that involves hazardous substances?
  • How can these cause harm?
  • How can you reduce the risk of harm occurring?

Always try to prevent exposure at source. For example:

  • Can you avoid using a hazardous substance or use a safer process – preventing exposure, eg using water-based rather than solvent-based products, applying by brush rather than spraying?
  • Can you substitute it for something safer – eg swap an irritant cleaning product for something milder, or using a vacuum cleaner rather than a brush?
  • Can you use a safer form, eg can you use a solid rather than liquid to avoid splashes or a waxy solid instead of a dry powder to avoid dust?

Check your trade press and talk to employees. At trade meetings, ask others in your industry for ideas.

If you can’t prevent exposure, you need to control it adequately by applying the principles of good control practice (http://www.hse.gov.uk/coshh/detail/goodpractice.htm)

Control is adequate when the risk of harm is ‘as low as is reasonably practicable’.

This means:

  • All control measures are in good working order.
  • Exposures are below the Workplace Exposure Limit, where one exists.
  • Exposure to substances that cause cancer, asthma or genetic damage is reduced to as low a level as possible.

COSHH Essentials

COSHH Essentials sets out basic advice on what to do to control exposure to hazardous substances in the workplace. It takes the form of straightforward advice in ‘factsheets’ called ‘control guidance sheets’. There are two types of sheets, industry-specific ‘direct advice sheets’ and ‘generic control guidance sheets’.

Direct advice sheets (click on the link: http://www.hse.gov.uk/coshh/essentials/direct-advice/index.htm)

First check the direct advice sheets listed by industry to see if there are any direct advice sheets for tasks or processes in your industry. If your industry is not listed don’t worry, you can use our e-tool to identify which generic control guidance sheets are appropriate.

COSHH e-tool (click on the link: http://www.hse.gov.uk/coshh/essentials/coshh-tool.htm)

When using the tool you will be prompted by questions to enter some basic information about the substance you are using, before being directed to the most appropriate generic control guidance sheet for you.

Frequently asked questions (click on the link: http://www.hse.gov.uk/coshh/essentials/faq.htm)

  • Why does COSHH essentials not list all of the R phrases/H statements that are on my Safety Data Sheet (SDS)
  • I can’t find my safety data sheet. What should I do?
  • I have just completed COSHH essentials, is this sufficient to use as my COSHH assessment?
  • Some of the information I need is missing from my safety data sheet. What should I do?
  • There isn’t a boiling point in the safety data sheet?
  • Why can’t I mix a liquid with a solid?

For more information, visit the HSE web page http://www.hse.gov.uk/coshh/, or contact us on 07896 016380 or at Fiona@eljay.co.uk

Contains public sector information published by the Health and Safety Executive and licensed under the Open Government Licence